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Texas Republican Senator Ted Cruz potentially violated ethics rules by failing to publicly disclose his financial relationship with a Caribbean-based holding company during the 2012 campaign, a review of financial disclosure and company documents by TIME shows. The relationship originated with a $6,000 investment Cruz made more than a decade ago in a Jamaican private equity firm founded by his college roommate.

When Cruz later reported the financial relationship in 2013, he failed to comply with Senate rules requiring full identification of the holding company and its location, triggering an inquiry by Senate Select Committee on Ethics staff and a second amended disclosure. After additional inquiries by TIME this week, Cruz said he is now in the process making further corrections to his disclosure.
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Cruz then received an inquiry from the Senate ethics committee staff about the listing, Cruz and his staff told TIME. The ethics staff told Cruz to amend his filing to indicate the nature of the promissory note, the entity that had issued it, the city in which the entity was located and the date the note had been issued.

Cruz did so in his Oct. 1 amendment, but that filing also contained errors, misnaming the holding company, incorrectly saying it was domiciled in Jamaica, and giving the wrong date for the promissory note. In the filing, Cruz, a former lawyer and magna cum laude graduate of Harvard Law School, lists a wide variety of assets held jointly with his wife, including mutual funds and blue chip stocks totaling between $1.5 million and $4 million. His wife is now an executive at Goldman Sachs.